DOW Laboratory Certification Program Update – 2014

1. DOW Laboratory Certification Program Update – 2014 Presentation to:KWWOA April 9, 2014 Department for Environmental ProtectionEnergy & Environment Cabinet To Protect and Enhance Kentucky’s Environment

2. Topics • Drinking Water Laboratory Certification • Wastewater Laboratory Certification • Common Laboratory Findings • Laboratory Certification Program Update • Web Page Update

3. Drinking Water Laboratory Certification Update

4. Drinking Water Program Update Program In-state Out-of-state Chemistry Labs 15 27 Microbiology Labs 46 2 Cryptosporidium 2 1 Radionuclides 0 9 Dioxin 0 6 Asbestos 1 3 PCBs (EPA508A) 0 2

5. Certificate + Analyte-Method List • Certificates are valid January 1st – December 31st of each calendar year • Only one certificate for laboratories with both Chemistry and Microbiology certification • Both Chemistry and Microbiology certificate packages include an analyte-method list • Analyte-method lists must include Minimum Reporting Limit (MRL)

6. Compliance Sample Results • DOW continues using SDWIS filters which will reject any results (analyte-method) that a certified laboratory is not certified for – this includes secondary contaminants • SDWIS filters also include the KY MRL – any laboratory non-detect result not meeting the MRL is flagged by the database • MRL must be < Required Reporting Limit

7. On-site Laboratory Audits • Both Chemistry and Microbiology laboratories will be audited at least twice every three years • Cryptosporidium audits have been completed for upcoming LT-2. Laboratories will be audited at least once more during the upcoming LT-2 monitoring period (2015-17) • Announced and Unannounced Audits

8. Upcoming Cryptosporidium LT-2 • All previously certified Cryptosporidium certified laboratories must recertify for upcoming LT-2 period (2015-17) • Check USEPA website for a list of currently certified Cryptosporidium laboratories • Contact DOW if you have any questions regarding Cryptosporidium certification

9. Laboratory Accountability Program • DOW will continue to utilize the Laboratory Accountability Program for laboratory reporting errors that are submitted to the state • First step in the process to downgrade/revoke a laboratory’s analyte-method certification • Laboratory Accountability Program has contributed to the reduction of the number of violations issued to public water systems

10. Proficiency Test Studies • Laboratories performing drinking water analyses are required to successfully complete one PT Study per analyte-method each year • Laboratories that fail two consecutive PT Study samples for the same contaminant must report to the state with a corrective action plan • DOW is pursuing electronic tracking of all PT Study results – in place by end of 2014

11. Wastewater Laboratory Certification Update

12. Laboratory Applications Status • Applications received = 36 • In-state = 23 • Out-of-state =13 • Certificates issued = 21 • Application deadline = October 1, 2014

13. Effective Dates of Certification • General Laboratories • January 1, 2014 – December 31, 2015 • Compliance samples = by January 1, 2015 • Field-only Laboratories • January 1, 2015 – December 31, 2016 • Compliance samples = by January 1, 2016

14. Application Common Issues • Incomplete submissions • QAP and/or SOP missing key elements • Quality control acceptance criteria • Analyte-method list incomplete/inaccurate • Reference methods are no longer approved • PT Study reports reference incorrect methods

15. Application Common Issues (cont) • Standard methods are not referenced properly: • SM 1234 A-year • PT reports do not contain the complete reference method (e.g. SM 2540 B-1997) • Colilert-18 for Fecal Coliform – must receive written approval from EPA Region 4

16. Audit Schedules • General Laboratories: • Laboratory audits began in 2014 • At least one audit each five years • Field-only Laboratories: • First audit performed by DOW Laboratory Certification Group and Field Inspector • All other audits performed by Field Inspectors

17. Commonly Audit Findings DRINKING WATER ONLY General Findings Chemistry Microbiology

18. General Audit Findings • KY regulation captures Standard Methods: • Drinking Water: • 18th, 19th, 20th, 21st and 22nd Editions • SM 18th , 19th and 20th = contained in regulation and EPA manual • SM 21st and 22nd = by ATP • SM 18th and 19th Editions are being phased out. Recommend 21st or 22nd Ed.

19. General Audit Findings (cont) • Traceable back to NIST – whenever possible • Eppendorf Pipets, Thermometers, Balances, Standards, Reagents, etc. • Utilize control charts (trend analysis) or document quality control acceptance limits • Notify DOW of key personnel changes • Utilize maintenance log books for instruments • Remember – document all observations!

20. Chemistry Laboratory Audit Summary • Methods used must be published in 40CFR141 or an EPA signed ATP on file at laboratory • Method must be capable of meeting KY MRL • Laboratory must demonstrate KY MRLs (e.g. reporting limit standard, RLS) • MDLs – annually (2-3 non-consecutive days) • IDC – performed by each analyst initially • ODC – performed by each analyst annually

21. Chemistry Audit Findings (cont) • All drinking water methods must be performed as written in the EPA approved method • All quality control samples must have an acceptance criteria and associated corrective action for unacceptable results • Documentation of preservation checks (VOCs) • Calibration curves – forced thru zero (0)

22. Microbiology Program Update DOW State Principle Microbiology Laboratory is MSU Water Quality Lab

23. Microbiology Program Update • DOW has established: • Initial Requirements for a Drinking Water Microbiology Laboratory • Microbiology Analyst Approval Process • PT Study Requirements • DOW does not track CEUs – laboratories are required to maintain all training records for review during on-site audit or upon request

24. Microbiology Laboratory Audit Summary • Perform EPA approved methods as written • Colilert-18 and 24 are treated as two methods • PT Studies – in accordance with EPA Manual • Colilert-18 for Fecal Coliform – must receive written approval from EPA Region 4 • Use bench sheets for analysis of PT Samples • Replace reference comparators when expired • Utilize internal sample tracking documents

25. Microbiology Audit Summary (cont) • Supervisors and QA Managers must meet credential requirements listed in EPA Manual • SOPs / QAPs must be reviewed/updated annually – document date • BACT samples must be at least 100 mL • DOC must be performed and documented • Strikeouts/overwrites – single line, date/initial • Analyst Signature/Initials must be on file

26. DOW Laboratory Certification Program Update

27. Technical Assistance • Updated list of certified laboratories • Hyperlink analyte-methods & status • Updated method – analyte code list • Fact Sheets • DOC Worksheet (IDC, MDL & RLS) • Control Charts – worksheet template

28. Training • On-going Wastewater Laboratory Certification Training: • Application Process • QAP • SOP

29. Web Pages DOW Main Page http://water.ky.gov Laboratory Certification http://water.ky.gov/permitting/Pages/labcert.aspx Drinking Water http://water.ky.gov/DrinkingWater/Pages/CertifiedLaboratories.aspx Wastewater http://water.ky.gov/permitting/Pages/WasteWaterCertification.aspx

30. General Email Address dowlabcertification@ky.gov

31. Drinking Water Website • Ongoing Improvements to the DOW website http://water.ky.gov/DrinkingWater/Pages/CertifiedLaboratories.aspx • Laboratory Certification Webpage Updates: • Useful information and documentation • DOC worksheets (IDC, MDL & RLS) • Minimum Reporting Limits listed • List of KY analyte codes and method codes • Approved PT Study Providers - Updated

32. Wastewater Website • KWLCP Application Form (6-13-2013) • KY Approved EPA Compliant Methods • Field Laboratory QAP and SOP • General Laboratory QAP and SOP • WW Analyte Method List TEMPLATE • KY WW Laboratory Certification Manual • Demonstration of Capability

33. DOW Laboratory Audit Team Frank Hall – Certification Program Manager Patrick Garrity – Laboratory Certification Officer Kevin Stewart – Certification Officer Arianna Lageman – Certification Officer Dr. Ted Pass – Certification Officer Tiffany Nolan – Laboratory Auditor Erich Cleaver – Laboratory Auditor

34. DOW Laboratory Audit Team (cont) John Williams – Laboratory Auditor Tabitha Aldridge – Laboratory Auditor Gabriel Tanner – Laboratory Auditor Jack Wiedo – Laboratory Auditor

35. Questions ?

36. Contact Information Patrick J. Garrity Laboratory Certification Officer Division of Water200 Fair Oaks Lane; 4th Floor Frankfort, KY 40601 Phone: (502) 564-3410 Fax: (502) 564-2741 Email: patrick.garrity@ky.gov